|Received:||7/16/2006 2:45:40 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:I have been a Quixtar Independent Business Owner (IBO) since September, 1999 and know that the proposed rules would adversely affect my business and the business of many IBO's on our team. When I became an IBO I was looking to add additional income and create some free time for me to spend with my family. I have achieved both goals, but am in the process of taking my business to the next level. When I registered, my sponsor shared the business plan with me and gave me a copy of the SA-4400 to review. I had questions and my sponsor either answered them directly or put me in contact with IBO's in his support team who answered my questions. I received what I considered to be full and complete disclosure. As I had owned a traditional business for a number of years, I understood that my success would primary depend upon my efforts and my use of the proven business system that other IBO's had used to build successful businesses. Given my understanding and belief that integrity plays a major role in any business (it certainly played itself out in my traditional business) that has a long-term view (i.e., there is no such thing as "get rich quick"), I chose to align myself with those who share that value. That being the case, we always have and always will be open and forthright in our dealings with prospective IBO's as well as those IBO's who are on our team. We share openly with prospective IBO's that we don't guarantee their success; that is totally up to them. It involves hard work and adherence to the proven system of building a business (similar to systems found in franchising). What we do provide is an atmosphere of success, where IBO's can apply themselves to achieve their goals. We openly state with prospects that the compensation plan does not pay money to IBO's for registering new IBO's. Money is only earned through the compensation plan if volume is created; that is, products are bought for personal use or sold to customers. We recommend to new IBO's that they buy an Initial Product Pack of products when they register; for this they earn Point Value (P.V.) , the basis of getting paid via our compensation plan. Total registration cost for a new IBO (including the Initial Product Pack) is $150 - $175. Here are my comments on the proposed rules and how they would affect my business: 1. 7 Day Waiting Period - this would adversely affect the growth of my business in that we are typically seeing at least 2 to 3 new IBO's register each week. We then schedule meetings for them at which they have prospects to whom we show the business presentation. The proposed rule would slow that growth down to a crawl. Not only would our business be adversely affected, but the new IBO's business would be adversely affected because of a slow down in numbers of new IBO's registering on their teams, but a slowdown in the volume (P.V.) of their businesses. This would directly cost them money. Bottom line - the proposed rule would affect my business profitability. Given that new IBO's can get their money back if they change their minds about pursuing their business, the proposed rule should be eliminated. 2. Requirement to provide references - this would adversely affect our business in that it's not outside the realm of possibility that another IBO could register someone with whom I've already invested time and money. Additionally, from a privacy concern, I don't want my name and information given to someone else's prospects. 3. Requirement to provide a "litigation list". From my previous business experience, the fact that my previous company was involved in a lawsuit had nothing to do with our integrity. A better solution would be to require Better Business Bureau membership. 4. Requirement for specific earnings disclosure - I never shared what I made from my traditional job with others; shouldn't have to do so here. I have more detailed comments but am limited by the 4,000 limit. Thank you.